comment letter

Joint Trades Letter on Debit Card Interchange Fees and Routing


Dear Ms. Misback:

The American Bankers Association (“ABA”), Consumer Bankers Association (“CBA”), Credit Union National Association (“CUNA”), National Association of Federally-Insured Credit Unions (“NAFCU”), and The Clearing House (“TCH”), which together represent virtually all of the Nation’s regulated financial institutions, write to request that the Board of Governors of the Federal Reserve System (“Board”) extend the effective date for the recent final rule amending Regulation II (12 C.F.R. Part 235, the “Final Rule”),  in order to provide debit card issuers, which are predominantly community banks and credit unions, time to implement the requirements of the Final Rule.

Banks and credit unions of all sizes provide innovative and competitive payments products and services to consumers and commercial customers. Unique to the American market, thousands of regulated financial institutions form a large and diverse network of payments providers that originate and receive funds. Financial institutions provide these payment services using a variety of technologies and vendors within product systems that are interrelated and often complex.

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